Privacy Notice Budget Rent A Car System, Inc.

Transcription

1 Privacy Notice 2016 Budget Rent A Car System, Inc.

2 Budget Rent A Car System, Inc. Privacy Notice Notice Last Updated: February 15, 2015 This is the United States privacy notice ( Privacy Notice ) of the Avis and Budget companies within the Avis Budget Group, Inc. and their subsidiaries and affiliates, including, without limitation Avis Rent A Car System, LLC, Budget Rent A Car System, Inc. and Budget Truck Rental, LLC (collectively, ABG, we, us, or our ). ABG has received TRUSTe s Privacy Seal signifying that this privacy policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. TRUSTe s certification covers only the ABG Websites, mobile sites and mobile applications that link to this TRUSTe approved privacy notice and that are displayed on our validation page. If you have questions or complaints regarding our privacy notices or practices, please contact us at abgprivacy@avisbudget.com If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe here Purpose of this Privacy Notice This notice describes the privacy practices we follow for the personally identifiable information ( PII ) that we collect, use and disclose through use of our products and services either offline or online. Our online operations include all of the websites of ABG (collectively, the Websites ). This Privacy Notice also explains how you can correct or change the PII we hold about you, or opt-out of receiving certain marketing materials. By submitting your personally identifiable information to us, you consent to ABG s use and disclosure of your PII as set forth in this Privacy Notice. If you do not agree with the terms of this Privacy Notice, please do not submit any information to ABG either offline or through our Websites. This Privacy Notice is incorporated into, and part of, the Terms of Use, which governs each ABG Website. Who is Covered under this Privacy Notice This Privacy Notice is applicable to PII that you provide to ABG. This Privacy Notice applies to all of the products, services, mobile sites, mobile applications, and Websites offered by ABG subsidiaries or affiliated companies. This Privacy Notice does not apply to those Avis or Budget locations that are owned and operated by an independent licensee that is neither owned nor controlled by ABG or any ABG affiliate or subsidiary. Each independent licensee collects PII and uses the PII for its own purposes. ABG does not control the independent licensee s use of this PII. For credit card transactions, the independent licensee - not ABG - collects and processes credit card information and receives payment for the vehicle rental services. Thus, the independent licensee is subject to the merchant rules of the credit card processors it selects. This Privacy Notice also does not apply to an independent licensee s website. These licensees may also use campaigns and other methods of telephone, electronic and direct mail solicitation without our consent or knowledge and are solely responsible for their content and methods of identifying and contacting addressees. What Personally Identifiable Information ABG Collects You generally are not required to provide us with PII when visiting our Websites. However, when you make a reservation, rent a vehicle, and/or join one of our programs, we need to collect certain information about you to provide our services. The service that you choose will determine what information we collect from you. Here are some examples of information we may collect from you: Name Address Home and/or Business Address Telephone Numbers at which we can contact you Date of Birth Payment Information (i.e. debit or credit card and expiration date - security code is obtained for transaction only and is not retained) 2

3 Information from your Driver s License or other Government issued identification (e.g., Passport) When you rent a vehicle, we may also record non-personally identifiable information about your rental (e.g. demographic information such as your age, gender, habits or preferences, where you rented the vehicle, where and when you returned the vehicle, payment arrangements, insurance preferences, gas consumption, mileage and other information related to the vehicle). This information is necessary in order to administer your rental reservation and/ or process your transaction. Other optional services such as OnStar which are provided and administered by an unaffiliated third party may collect other information such as geo location information. ABG does not collect, process or retain any of the third party information. You should familiarize yourself with the privacy practices of such third parties before selecting that additional service. We may also need certain information from you when you request any of the following services or equipment: Special Needs/Optional Equipment; Special Offers/Discounts; Partner Member Numbers; use of a corporate or other discount number and other vehicle preferences. For example, if you wish to use a discount that ABG provides to members of an association/affiliate to which you belong, we may collect information about your membership to verify and provide you with the correct discount for our services. In addition, to better serve our more frequent renters, ABG offers customized rental services on a membership basis such as Preferred Service, President s Club, Chairman s Club, Fastbreak or the Weekender Club. If you wish to join and request one of these services, ABG may need more information than is required for providing standard vehicle rental service in order to provide you with these customized services. When you download and use our services, we automatically collect information on the type of device you use, operating system and application version. If you choose to allow it, our applications and mobile sites may collect location markers (geolocation data) using a GPS device built into or attached to your computer or mobile device or other methods, such as mapped wifi routers or cell identifiers from broadcast towers. You may adjust the settings of your computer or mobile device to turn off transmission of geolocation data at any time by updating the settings on your device. Your telephone calls and correspondence with us may be recorded or monitored for quality control, training and similar purposes. By using these communication methods you are consenting to the recording or monitoring of your calls and s. How ABG Collects Personally Identifiable Information The PII we collect from you will be with your consent and will depend on how you use our services. We may collect this information directly from you by telephone, fax, postal mail, , at the counter, upon completion of an application or enrollment form, or through your use of our Websites, mobile sites, mobile application, or the Internet. To the extent you use our Websites, we may also collect information about your use of our Websites, transactional and account information, and other information related to communications to our Websites. We may also collect information about you indirectly through a travel agent, an account program in which you or your employer participates or through one of our partner programs when you deal with us through those means. Additionally, our affiliates and third parties may provide us with information about you. You may choose not to provide some of your PII to us, but this may prevent us from providing our services to you, or limit our ability to provide you with the level of service that you would otherwise expect from us. How Personally Identifiable Information is Used and Disclosed by ABG Usage To provide the level of service we believe you expect from us, we may use your PII for the following purposes: Provide and administer the services that you request, and communicate with you regarding such services and offerings; Coordinate your travel or travel information and profile with those third party services with which you have registered and where you have you explicitly authorized us to do so. To discontinue such coordination or information sharing, you may be required to initiate the change through the third party service; Research, develop, manage, protect and improve our Websites and services; Maintain and develop our service-oriented software and other business systems; and Analyze data, or have a third party do so on our behalf. We may also use your information - both PII and non-personally identifiable information - for other purposes. For example, PII may be needed to process and track your transactions or to send you information about our affiliates and business partners products and services and other information and materials that may be of interest to you. If you use our Websites, we may also use your information to evaluate what portions of our Websites are visited more often than others, determine where visitors came from, where they go, and how long they stay on a particular page, or on our Websites in general. 3 From time to time, we also may combine your PII with information obtained from other sources, including third parties, in order to provide you with more customized services and product offerings. To do this, it is often necessary to share your information with trusted vendors and business partners, such as companies that manage accounts, offer affinity, frequent-user, and reward programs, and companies that perform marketing services and other business operations for us. For more information, see below under Disclosing.

4 Disclosing We may disclose your PII to affiliated and non-affiliated organizations including, for example: To your company or organization if you use our services under a corporate or other commercial account; To one of our program partners (e.g. if you are a member of an affiliate program, such as a relocation company or frequent traveler program and you have asked us to send them details of your rental agreement with us to obtain your benefits from that program); To entities that provide services on our behalf; To any intermediary you use, such as a travel agent, broker or booking engine, in relation to any aspect of your rental; To independent licensees for use in providing the services and offerings which you have requested and to communicate with you regarding such services and offerings; To your credit card issuer in order to process a transaction and for other purposes related to the transaction; To credit reporting and fraud checking agencies; To debt collection agencies, if you fail to pay monies owed to us; To government or private organizations responsible for the processing or handling of traffic or parking related violations; To driver licensing authorities, directly or through intermediary organizations, when needed to verify compliance with ABG s safe driver criteria for qualified drivers and/or to verify license information; and To government, regulatory and law enforcement agencies where the disclosure is required or authorized by law, and otherwise as we believe is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our Websites properly, or to protect or defend our rights or the rights or well-being of our employees, users or others or if you are involved (or are suspected by governmental authorities or our security or fraud prevention groups to be involved) in any illegal activity, even without a subpoena, warrant or court order. We may disclose your PII to our affiliates and non-affiliated business partners for their use both on our behalf and for their own business purposes. For example, our affiliates and business partners may use such PII to send you information about their products and services and other information and materials that may be of interest to you. You may opt-out of us disclosing your PII for these purposes through one of the methods described in this Privacy Notice. We may share your PII with other non-affiliated third parties, such as entities that provide services for our Websites or for our business (e.g., advertisers, ad servers, content providers, services providers, credit card processors, data processors, website development and support, fulfillment services providers, list hosting companies and distribution companies) that use such PII on our behalf consistent with this Privacy Notice. These types of third parties are not permitted to use your PII for any secondary purposes. We may also transfer or assign your PII to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation. Special Note to Non-U.S. Visitors This Privacy Notice is intended to meet the laws and requirements of the United States, which may not necessarily be consistent with the laws and regulations of your home country. Any information that you provide to ABG will be treated in accordance with this Privacy Notice. We operate globally so we may need to transfer your PII to locations outside of the United States as part of our normal business operations. If the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected. Website and Internet Privacy If you use our Websites or otherwise interact with us via the Internet, the following privacy-related policies also apply: Website Tracking Technologies Technologies such as: cookies, tags, scripts, and beacons are used by us and our partners (software vendors, advertisers, ad servers, content providers, and services providers). These technologies are used in collecting information about you and your usage activity on this and other websites, enhance the functionality of our Websites and services, make transactions and other activities more convenient and efficient. We use cookies to store information about your travel preferences or rental history so you don t have to tell us repeatedly your preferences, we also use cookies to track Website usage trends and patterns. This helps us understand our users needs better and improve areas of our Websites. 4

5 Do Not Track Mechanisms We do not respond to Web browser do not track signals at this time. We await the result of work by the policy community and industry to determine when such a response is appropriate and what form it should take. We do allow you to exercise choice regarding the collection of information by third parties about your online activities over time and across third-party Web sites or online services for online interest based advertising purposes by going to or IP Addresses An IP address is a unique number that is automatically assigned to your computer whenever you are surfing the Internet so that your computer can be identified by the main computers, known as Web servers, that deliver Web pages to your browser. Collecting your IP address allows us to gather useful information and data about our customers use of the site, such as the Web pages viewed on ABG collects IP addresses for the purposes of: helping us diagnose problems with our main computers, for system administration, to report aggregated information to our business partners, and to audit the use of our Website. When users request Web pages from our Web Site, our Web servers log the User s IP address. We do not normally link IP addresses to anything personally identifiable, which means that a user s session will be logged, but the user will remain anonymous to us. For example, we collect and/or track the home server domain name, the type of computer, and the type of Web browser used by you to access this Web Site. Such collection and tracking information is gathered by us as you navigate through our Websites, and will be used by us for our business purposes only. In select instances, we may use IP addresses to help us identify you when we feel it is necessary to enforce compliance with our Website Terms of Use or to protect our service, site, users or others. We also gather certain information automatically and store it in log files. This additional information may include browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to information we collect about you. Third Party Use of Technology We may use third-party servicing technology and service providers to serve ads on our behalf across the Internet and sometimes on our Websites. They may collect non-personally identifiable information about your visits to our Websites, and your interaction with our products and services. They may also use non-personally identifiable information about your visits to send you targeted advertisements for goods and services. This information is collected through the use of a pixel tag, or similar technology which is industry standard technology used by most major websites. If you would like more information about this practice and to know your choices about not having this non-personally identifiable information used, please visit managing/opt_out.asp or We may also share Website usage information about visitors to our Websites with selected third parties for the purpose of targeting our Internet banner advertisements on our Websites and other websites. To do this, we use web beacons and cookies provided by our third-party ad server on our Site. In connection therewith, such third parties may have access to and use non-personalized information about your online usage activity. The use of advertising cookies and web beacons sent by such third-party Web servers is standard for commercial activity in the Internet industry. Get more information about our third-party ad server, its use of cookies and how to opt-out. Web Beacons Web pages may contain an electronic file called a web beacon that allows a website to count users who have visited that page or to access certain cookies. We are currently partnering with Yahoo! who utilizes web beacons in the following ways: Yahoo! uses web beacons to conduct research on behalf of certain partners on their websites and also for auditing purposes. Information recorded through these web beacons is used to report aggregate information about Yahoo! users to our partners. This aggregate information may include demographic and usage information. No PII about you is shared with partners from this research. When conducting research, Yahoo! s practice is to require their partners to disclose the presence of these web beacons on their pages in their privacy policies and state what choices are available to users regarding the collection and use of this information. You may choose to opt-out of Yahoo! using this information for this research. Note: This opt-out applies to a specific browser rather than a specific user. Therefore you will have to opt-out separately from each computer or browser that you use. 5 We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the

6 application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile app. Visiting Third-Party Websites Our Websites may contain links or references to third party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party websites and our Privacy Notice does not apply to such websites. We encourage you to check the terms of use and privacy policies of such sites before disclosing any PII on those sites. Occasionally, when linking to a third-party website from our Websites, you may still see an ABG affiliate logo or an ABG affiliate website frame. This is to provide you with a seamless experience when visiting our Websites. In these cases, you are no longer on our Websites but the third-party website, and therefore the information collection practices of the third party s website may differ from ABG s. The privacy notice of the third party site will govern how information collected from you is used by the owner of the website. You can always know what website you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser. Linking your ABG Accounts to Your Social Profiles Social Authentication In order to provide you with more personalized services, we may give you the option of linking your social profiles with your ABG accounts on our Websites. Currently, some of our Websites allow you to link social profiles from Facebook, Twitter, LinkedIn, Google and Windows Live. We may add or remove the availability of any or all platforms at any time in our sole discretion. This functionality is entirely optional for all users and you may link or unlink your account(s) at any time. What Information is Collected from Your Social Profiles and What It s Used for If you exercise the option to link your social profile to any of our Websites, we may collect PII and additional information from your social profiles, which will be used by ABG and agents acting on our behalf to customize your ABG customer experience. Some examples of the type of information we may collect from these social profiles include: profile picture, gender, marital status, sexual preference, birthday, list of friends (but not the information on your friends social profiles unless they have also linked their profiles) Professional Information such as prior and current work history Personal Likes, Activities and Interest Information The information we collect may be used to: Serve you customized offers and deals on our Websites Send you offers with special deals and discounts Send you offers by mobile phone text messages Update your profile information on our Websites Publish check-in and check-out information to your linked social media accounts Share your upcoming trips with friends View your friends that have linked their profiles upcoming trips Unlinking Your Accounts You may unlink your social profiles at any time. In order to unlink your profiles, you must log into each ABG account that has been linked, click on the Social Media Preferences tab, and then select Unlink next to the social media channel you wish to unlink. Social Sharing 6 In an effort to provide our customers with new ways of sharing content, we have enabled some of our online content to be shared on social websites through hosted sharing links and icons. Users who share content and links through their social media profiles should be aware that all activities of this

7 nature are public. Please note, when you share (with or without adding your own comments) any of our content on your social media profile, that action is governed by the privacy policy of that social media platform, and not ABG s Privacy Notice. We do not track or store a record of those comments or actions. If you choose to participate in posting or sharing activities, you are electing to share and display such public activities via our Websites. Due to the public nature of your posting or sharing your posts may be included in RSS feeds, APIs and made available to other websites via other formats. As a result, your public activities may appear on third-party websites, blogs, or feeds. WE ARE NOT RESPONSIBLE FOR ANY PII YOU CHOOSE MAKE PUBLIC VIA YOUR SHARED POSTS. How We Protect the Security of Personally Identifiable Information The security of your PII is important to us. We exercise reasonable care in implementing generally accepted standards of security to protect your PII from loss, misuse and unauthorized access, disclosure, alteration or destruction, such as firewalls and Secure Socket Layer (SSL) encryption for some of your more sensitive PII (such as credit card information and state ID numbers). It is our policy to retain PII for only as long as we believe appropriate for the purposes for which the PII was collected or as required by applicable law. Unfortunately, perfect security does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we take reasonable efforts to protect your PII, we cannot guarantee that PII stored on our servers, or transmitted to or from a user, will be free from unauthorized access. By using our Websites and corresponding with us, you acknowledge that you understand and agree to assume these risks. You are responsible for maintaining the confidentiality of your account passcode, membership numbers and pin numbers, and you will be responsible for any access to or use of our Websites by you or any person or entity using a passcode provided to you, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. In the event of the unauthorized use of your passcode, account, or membership number, or any other breach of security involving your information as it pertains to ABG, you agree to immediately notify us. It is your sole responsibility to ensure that you exit from your account at the end of each session, control the dissemination and use of your passcode, control access to and use of your account and membership number, and notify us when you desire to cancel your account on our Websites. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision. It is our policy that we will never request your sensitive PII, such as your credit card number, passcode, membership number or pin number, in an , text or on a website that is not located at the domain name used by ABG or an affiliate (for example Avis.com, Budget.com Budgettruck.com). If you receive an or other correspondence requesting that you provide any such information via or to a website that is not on such domain name, please do not provide such information, and report such request to our privacy officer at budgetcustomerservice@budget.com. In the unlikely event that we have reason to believe that the security of your PII in our possession or control may have been compromised, we will notify you consistent with the applicable laws and regulations. If a notification is appropriate, we will do so as promptly as possible under the circumstances. If we have your current address on file, we may notify you by . How to Correct or Update Personally Identifiable Information that ABG Maintains If you have provided your PII to us, you can update the PII we hold about you. You play an active role in assisting ABG to maintain the accuracy of your PII. Your prompt notification to us of any changes to your PII will assist us greatly in keeping your information accurate and up-to-date. If we don t agree to make the changes, you may challenge our decision. You may update some if your information by logging into your account and editing your profile. If you wish to contact us to access or correct your PII we have, or to inquire or provide feedback about our privacy practices, you can us directly at budgetcustomerservice@budget.com or write to us at: Budget Rent A Car System, Inc. 6 Sylvan Way Parsippany, NJ ATTN: Privacy Officer We will respond to any access requests within 30 days of our receipt of the request. For customer service issues, please us at budgetcustomerservice@budget.com. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at budgetcustomerservice@budget.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. How to Opt-Out of Receiving Marketing Materials from ABG 7 You can opt-out of our use and disclosure of your PII for marketing purposes and customer satisfaction surveys, and/or withdraw your prior consent for

8 same, by the methods provided below. Upon requesting an opt out, your consent will be withdrawn., However, please note that it often takes some time to process these requests. Therefore, it is possible that you may receive promotions scheduled prior to our receipt of your withdrawal of consent. To opt-out of Campaigns: You may reply to a promotional or marketing that you have received from us with the word Unsubscribe in the subject line or you can us directly at budgetcustomerservice@budget.com. (If you use more than one address, then send your opt-out from each of your addresses.) To opt-out of any other promotional mailings from ABG and our partners: you may visit us at, or you may write to us at: Budget Rent A Car System, Inc. 6 Sylvan Way Parsippany, NJ ATTN: Privacy Officer For customer service issues, please us at budgetcustomeresrvice@budgetgroup.com. We may also provide additional methods for you to opt-out of having your PII used or disclosed for promotional and marketing purposes, such as by clicking on a checkbox located on the page of our Websites on which your PII is collected, or otherwise made available when you make reservations. Please note that your option not to receive promotional and marketing material: (a) will not preclude us from corresponding with you, by or otherwise, regarding your preexisting business relationship with us (e.g., your account status and activity or our responses to questions or inquiries you pose to us, or confirmations for existing reservations); (b) will not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your PII for our internal business purposes; and (c) will not preclude us from disclosing your PII as described in this Privacy Notice for purposes other than sending you promotional and marketing materials. Social Media (Features) and Widgets Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. Children s Privacy Our Websites are not directed to children under the age of 13. If you are under the age of 13, then please stop using our Websites or our products and services and do not provide us with PII of any kind whatsoever. It is our policy not to knowingly solicit children under the age of 13 for PII or otherwise contact children for any purpose. Further, it is ABG s policy to not knowingly allow children under the age of 13 to use our Websites or our products and services. We encourage parents and guardians to take an active role in monitoring their children s use of the Internet. It is possible that by fraud or deception, we may receive the PII of children under the age of 13. If we are notified or otherwise become aware of this, we will immediately delete the PII from our servers. If you want to notify us of our receipt of PII by children under the age of 13, please contact our privacy officer at budgetcustomerservice@budgetgroup.com. Some links on our Websites may possibly lead to the websites of third-parties that are directed to children. ABG does not control these third parties and is not responsible for the actions of our third party business partners. We encourage you to check their terms of use and privacy policies for such information that address children s privacy. Your California Privacy Rights If you are a California resident, you may have the right to request and receive certain information about our disclosure of personal information to third parties for their direct marketing purposes, and your choices with respect to such disclosures. However, our policy is not to share your personal information with third parties unless you first opt-in to such disclosure or are first given the opportunity to opt-out. This practice is disclosed in the preceding sections of this Privacy Policy. If you still wish to learn more about our compliance with this requirement, you may contact us using the contact information provided below. Applicable Law and Jurisdiction This Privacy Notice will be governed by the laws of the State of New Jersey, without regard to its conflict of law principles. By providing any PII to us, you fully understand and unambiguously consent to the transfer of such PII to, and the collection and processing of such PII in, the United States and other countries or territories. You agree that any cause of action that may arise under this Privacy Notice will be commenced and be heard in the appropriate court in Morris County in the State of New Jersey. You agree to submit to the personal and exclusive jurisdiction and exclusive venue of the courts located within Morris County in the State of New Jersey or the United States District Court for the District of New Jersey. 8

9 Changes to this Privacy Notice This Privacy Notice applies to all information we collect or receive, on or after the effective date of this Privacy Notice, from individuals who provide us with such information for the purpose of obtaining products and services from ABG or using our Websites. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice. If we materially change the way your personal information will be used, we will notify you by way of either prominent posting on our Website(s), and/or postal mail prior to the change becoming effective. We encourage you to periodically review this Privacy Notice in order to keep apprised of any changes. Privacy Officer a. Mail: Privacy Officer, Avis Budget Group, Inc., 6 Sylvan Way, Parsippany, NJ b. Phone: c. Fax: d. ABGprivacy@avisbudget.com FOR CUSTOMER SERVICES ISSUES, PLEASE CONTACT: Budget Customer Service Tel: budgetcustomerservice@budgetgroup.com U.S. Mail: P.O. Box Tulsa, OK Hours of Operation: 7:30 a.m. - 7:30 p.m. CST Budget Truck Rental Customer Service Tel: btr-customerservice@avisbudget.com U.S. Mail: P.O. Box Tulsa, OK Hours of Operation: 7:30 a.m. - 7:30 p.m. CST About the ABG System 9 Avis Budget Group is a leading global provider of vehicle rental services through its Avis and Budget brands, with 10,000 rental locations in approximately 175 countries around the world. Avis Budget Group operates most of its car rental offices in North America, Europe and Australia directly, and operates primarily through licensees in other parts of the world. Avis Budget Group has approximately 29,000 employees and is headquartered in Parsippany, N.J. For more information, visit

10 Budget Rent A Car System, Inc.